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Home My WebLink About20163678.tiffCOLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 December 2, 2016 Dear Sir or Madam: On December 8, 2016, the Air Pollution Control Division will begin a 30 -day public notice period for Edge Energy, LLC - Long 22-B. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure Publ;c, (.v ew v iiwilco 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickentooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer CC PL. C CM / —tP) , Mt.( P6) PuiCriz/CNfJm fGK3 t o7f7/CCo 2016-3678 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Edge Energy, LLC - Long 22-B - Weld County Notice Period Begins: December 8, 2016 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Edge Energy, LLC Facility: Long 22-B Well production facility NENW Section 22 Ti N R65W Weld County The proposed project or activity is as follows: Well production facility with condensate and produced water storage, hydrocarbon liquid loadout, and an engine for VRU compression. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analyses, and a draft of Construction Permits 16WE1136 and 16WE1137 have been filed with the Weld County Clerk's office. A copy of the draft permits and the Division's analyses are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air- permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Andy Gruel Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us COLORA©O 1 I •' t Qttt, Colorado Air Permitting Project Version No. 1.00 Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Andy Gruel_ 355066 11/1/2016 11/29/2016 Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry segment? Is this facility located in a NAAQS If yes, for what pollutant? non -attainment area? ❑ Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Edge Energy, LLC 123 9EEC Long 22-8 Pad NENW Section 22 T1N R6SW Exploration & Production Well Pad Oil Natural Gas Production & Processing Yes ❑ Particulate Matter (PM) ❑ Ozone (NOx & VOC) AIRs Point # Emissions Source Type Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 Produced Water Storage Tank Yes GP08 new GP08 reg 002 Hydrocarbon Liquid%Loading No 16WE1136 1 Yes Permit Initial Issuance 003Condensate Storage Tank... yes """: 16WE1137 1 ;- Yes Permit Initial Issuance 004 Natut I Gas RICE Yes GP02 new GP02 reg Section 03 - Description of Project Applicant proposes to construct and operate the above E&P well production facility equipment. Section 04 - Public Comment Requirments Is Public Comment Required? If yes, why?" Yes n 25 tons per year in Non -Attainment Area Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?2 If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, explain what programs and which pollutants here: Title V Operating Permits (OP) : VOC Non -Attainment New Source Review (NANSR): VOC Is this stationary source a major source? If yes, explain what programs and which pollutants here: No' Yes 123-9EEC-002 16WE1136 CP1 APEN rec'd 11/1/16 Loadout of condensate to tank trucks. Emissions are not controlled. Emissions Inventory Analysis Applicant used state default emission factors for condensate loadout. Requested throughput: 131400 barrels/yr Emission Uncontrolled factor Emissions Uncontrolled (lb/bbl) (Ib/yr) Emissions (tpy) VOC 0.236 31010 15.51 Benzene 0.00041 54 0.03 n -Hexane 0.0036 473 0.24 Regulatory Considerations Is this site considered an exploration and production location (e.g. well pad)? Yes If yes, review the following two exemptions for applicability: Does the operator unload less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average b N/A If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section II.D.1.1 Does this operator unload less than 6,750 bbls per year of condensate via splash fill or 16,308 bbls per year of condensate via submerged fill procedure? No If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section II.D.1.1 Is this site located in an ozone non -attainment area? Yes If yes, this source is subject to Reasonably Available Control Technology (RACT) requirements under Regulation 3, Part B Section III.D.2.a. This requirement may be met using "submerged fill" and/or vapor balance with emissions routed to an emissions control device. Is this facility classified as a major source of HAPs? No If yes, evaluate if 40 CFR, Part 63, Subpart EEEE "Organic Liquids Distribution" MACT provisions apply Does this facility involve the loading of refined crude/condensate in the form of "gasoline" no If yes, proceed to evaluate the following: Is this facility classified as a "Terminal" as defined per Regulation 7, Section VI.C.2.a? no If yes, the provisions of Regulation 7, Section VI.C.2 may apply Is this facility classified as a "Bulk Plant" as defined per Regulation 7, Section VI.C.3.a? no If yes, the provisions of Regulation 7, Section VI.C.3 may apply SCC Coding Emissions Factor P (lb/1,000 gallons) V 5.6190 lb/1,000 gallons B 0.0098 lb/1,000 gallons n 0.0857 lb/1,000 gallons 40600132: Crude Oil: Submerged Loading (Normal Service) Use if S = 0.6 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name Edge Energy, LLC 123 9EEC Long 22-8 History File Edit Date Ozone Status 11/29/2016 Non -Attainment EMISSIONS - Uncontrolled (tons per year EMISSIONS With Controls (tons per year POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S 5O2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACIUTY TOTAL 0.0 0.0 0T 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Fec:lty- No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 O0 0.0 0.0 0.0 0.0 0.0 00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 00 001 GPO Produced water storage, 500 bbl 31.9 3.5 1.6 0.2 new GP08 002 16WE1136 Loadout 15.5 0.3 15.5 0.3 State default EFs 003 16WE1137 Condensate storage (1000 bbl) 04 205.8 1.6 3.5 0.4 10.3 1.6 02 SSEFs accepted 004 GP02 GM FX10 (5.7L), ern 10CHMM305270039, 155 hp 21.0 1.0 16.5 0.2 1.5 1.0 16.5 0.2 new GP02 APEN-Exempt / lnsignificants XA Heater 0.0 00 0.2 0.0 0.1 0.0 0.0 00 0.2 0.0 0.1 0.0 XA Fugitives 0.0 0.0 0.0 0.0 FACILITY TOTAL 0.0 0.0 0.0 0.0 21.5 254.3 0.0 18.2 7.5 0.0 0.0 0.0 0.0 2.0 28.5 0.0 18.2 0.8 VOC: Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Minor (PSD and OP) HAPS: Minor HH: Minor ZZZZ: Minor Permitted Facility Total 0.0 0.0 O0 0.0 21.3 254.3 0.0 18.1 7.5 0.0 0.0 0.0 0.0 1.8 28.4 0.0 18.1 0.8 Excludes units exempt from permitx/APENs (A) Cha ge in Permitted Emissions 0.0 0.0 0.0 0.0 1.8 28.4 0.0 18.1 Pubcom required based on greater than 25 tpy increase in VOC for CP points in NAA Note 1 Total VOC Facility Emissions (point and fugitive) (A) Change in Total Permitted VOC emissions (point and fugitive) 28.5 Facility is eligible for GP02 because < 90 tpy Project emissions less than 25150 tpy 28.4 Note 2 Page l of 1 Printed II/29/2016 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Edge Energy, LLC County AIRS ID 123 Plant AIRS ID 9EEC Facility Name Long 22-B Emissions - uncontrolled (Ibs oer year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP08 Produced water storage, 500 bbl 1707 5364 3.5 002 16WE1136 Loadout 54 473 0.3 003 16WE1137 Condensate storage (1000 bbl) 803 493 43 193 5366 85 3.5 004 GP02 GM FX10 (5.7L), sn: 10CHMM3052700 237 33 31 18 36 0.2 APEN-Exempt / Insignificants XA Heater 6 0.0 XA Fugitives 1 1 1 2 4 1 0.0 TOTALftpy) 0.1 0.0 0.0 1.3 0.2 0.0 0.1 5.6 0.0 0.0 0.0 0.0 7.5 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text uncontrolled emissions < de minimus Emissions with controls (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP08 Produced water storage, 500 bbl 86 269 0.2 002 16WE1136 Loadout 54 473 0.3 003 16WE1137 Condensate storage (1000 bbl) 40 25 2 10 268 4 0.2 004 GP02 GM FX10 (5.7L), sn: 10CHMM30527002 237 33 31 18 36 0.2 APEN-Exempt / Insignificants XA Heater 6 0.0 XA Fugitives 1 1 1 2 4 1 0.0 TOTALf(tpy) 0.1 0.0 0.0 0.1 0.0 0.0 0.0 0.5 0.0 0.0 0.0 0.0 0.8 1239EEC.xlsx 11/29/2016 Colorado Air Permitting Project Version No. 1.00 Project Details Review Engineer: Andy Gruel Package #: 355066 Received Date: 11/1/2016 Review Start Date: 11/29/2016 Section 01- Facility Information Company Name: Edge Energy, LLC County AIRS ID: 123 Plant AIRS ID: 9EEC Facility Name: Long 22-B Pad Physical Address/Location: NENW Section 22 T1N R65W Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production-& Processn Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ❑ Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application ❑ Particulate Matter (PM) ❑ Ozone (NOx & VOC) AIRs Point # Emissions Source Type Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 Produced Water Storage Tank , Yes"% . y G P08 new GP08 reg 002 itrocarbon Liquid t sading ' " No 16WE1136 1 Yes mit;Initial..... Issuance 003densate Storage Tank Yes „"" 16W E1137 1 Yes Perry it Initial .. . nuance 004 Natural Gas RICE Yes „ GP02 new GP02'reg Section 03 - Description of Project Applicant proposes to construct and operate the above E&P well production facility equipment. Section 04 - Public Comment Requirments Is Public Comment Required? If yes, why?1 Gi er year in Non -Attainment Area Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?2 If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, explain what programs and which pollutants here: Title V Operating Permits (OP) : VOC Non -Attainment New Source Review (NANSR): VOC Is this stationary source a major source? If yes, explain what programs and which pollutants here: Condensate Storage Tank(s) Emissions Inventory Section 01- Adminstrative Information Facility AIRS ID: 123 County 9EEC 003 Plant Point Section 02- Eauioment Description Details Detailed Emissions Unit Two (2) 500 -bb( fixed roof atmospheric condensate; Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: combustor with minimum 95% canto Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions • Storage Tank(s) Actual Condensate Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Condensate Throughput = Secondary Emissions - Combustion Device(s) Heat content of waste gas = Volume of waste gas emitted per BBL of liquids produced = Actual heat content of waste gas routed to combustion device = Request heat content of waste gas routed to combustion device = ,500'.. Barrels (bbl) per year ,400! Barrels (bbl( per year Barrels (bbl) per year 2226.44'.. Btu/scf scf/bbl Actual Condensate Throughput While Emissions Controls Operating = 8,458 MMBTU per year 10,150 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 10,150 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Pollutant PM2.5 Condensate Storage Tanks Uncontrolled E.F. (lbs/bbl Condensate Throughput) Controlled E.F. (lbs/bbl Condensate Throughput) rN ` X __ __ e MInitmmm ItTMEM Control Device Uncontrolled E.F. (Ibs/MMBtu waste heat combusted) Uncontrolled E.F. (lbs/bbl Condensate Throughput) 0.0000 Emissions Factor Source Citation 0.068!.'.'.'.'.'. 0.0000 0.0053 3,132 0.806 0.0037...... 0.0006 0.00031 0.00019 0.00002 0.00007 0.00204 0.00003 =MEM %NNW% NNW VIA:Wilk NN Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) PM10 PM2.5 NOx VOC CO 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.3 0.3 0.35 0.3 0.3 205.8 205.8 10.29 171.5 8.6 1.6 1.6 1.57 1.3 1.3 Hazardous Air Pollutants Potential to Emit Uncontrolled (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 IMP 4.01E-01 4.0E-01 2.0E-02 3.3E-01 1.7E-02 2.46E-01 2.5E-01 1.2E-02 2.1E-01 1.0E-02 2.13E-02 2.1E-02 1.1E-03 1.8E-02 8.9E-04 9.64E-02 9.6E-02 4.8E-03 8.0E-02 4.0E-03 2.68E+00 2.7E+00 1.3E-01 2.2E+00 1.1E-01 4.25E-02 4.3E-02 2.1E-03 3.5E-02 1.8E-03 ection 06- Regulatory Summary Ana Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section XII, as provided bel Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XII.G Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3, a Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2, as provide Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 Regulation 8, Part E, MAC Subpart HH Storage Tank is not subject to MAR HH (See regulatory applicability worksheet for detailed analysis) Uncontrolled PTE (lb/yr) 803 493 43 193 5366 85 Controlled PTE (lb/yr) 40 25 2 10 268 4 109,500'.. Barrels (bbl) per year 2 of 3 K:\PA\2016\16W E1136.CP1.xlsm Condensate Storage Tank(s) Emissions Inventory Section 07- Initial and Periodic Samoline and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emisions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and intial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Applicant modeled emissions using Promax model, basedon a model throughput of 131400 bpy which matches the PTE throughput. The input data was a pressurized liquid sample taken from the on - site well (Long 22-15-6NCH) collected 9/7/20I6. The flash aid workingfbreathingemissions from the Promax model output were divided bythe modelthroughputto arrive at the emission factors listed NOk and CO emissions were based onthe Promax model output, with a heating value of 222644 Btu/scf, and a gas volume of 12.6633 fviscf/d. Dividing this gas volume by the PTEttitoughput of .'.131,400 bpy (360 bpd) gives a gas volume of 34.6941 scf/bbl, which was used in the calculations in Sections 03 and 04 above. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point p 003 Process U 01 SCC Code Uncontrolled Emissions Pollutant Factor Control % Units NOx 0.1251 0 lb/1,000 gallons condensate throughput VOC 74.5679 95 lb/1,000 gallons condensate throughput CO 0.5701 0 lb/1,000 gallons condensate throughput Benzene 0.1455 95 lb/1,000 gallons condensate throughput Toluene 0.0893 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.0077 95 lb/1,000 gallons condensate throughput Xylene 0.0349 95 lb/1,000 gallons condensate throughput n -Hexane 0.9723 95 lb/1,000 gallons condensate throughput 224 TMP 0.0154 95 lb/1,000 gallons condensate throughput 3 of 3 K:\PA\2016\ 16WE1136.CP1.xlsm COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name Edge Energy. LLC 123 9EEC Long 22-B History File Edit Date Ozone Status 1029/2016 Non -Attainment ISSIONS With Controls (tons per year POINT AIRS ID PERMIT Descnpdon PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H25 502 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facaitetotal 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 O0 O0 0.0 001 GPO Produced water storage, 500 bbl 31.9 3.5 1.6 0.2 new OPUS 002 16WE1136 Loadout 15.5 0.3 15.5 0.3 State default EFs 003 16WE1137 Condensate storage (1000 bbl) 0.4 205.8 1.6 3.5 0.4 10.3 1.8 0.2 SSEFs accepted 004 GP02 GM FX10 (5.7L), sit. 10CHMM305270039, 155 hp 21.0 1.0 16.5 az 1.5 1.0 16.5 0.2 new GP02 APEN-Exempt / Insignlficants XA Heater 0.0 0.0 0.2 0.0 0.1 0.0 0.0 0.0 02 0.0 a1 0.0 XA Fug6Aves 0.0 0.0 0.0 0.0 FACILITY TOTAL 0.0 0.0 0.0 0.0 21.5 254.3 0.0 18.2 7.5 0.0 0.0 0.0 0.0 2.0 28.5 0.0 18.2 0.8 VOC: Syn Minor (NANSR and OP) NOR: Minor (NANSR and OP) CO: Minor(PSD and OP) HAPS: Minor HH: Minor ZZZZ: Minor Permed Facility Total 0.0 0.0 O 0 0.0 21.3 254.3 0.0 18.1 7.5 0.0 0.0 0.0 O 0 1.8 28.4 0.0 18.1 0.8 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.0 0.0 0.0 O0 1.8 28.4 0.0 18.1 Pubcom required based on greater than 25 tpy increase in VOC for CP points in NAA Note 1 Total VOC Facility (C) Change in Total Permitted VOC Emissions (point and fugitive) emissions (point and fugifive) 26.5 Fadis eligible for GP02 because < 90 tpy Proled emission5less than 25(50 Toy 204 Note 2 Page 1 of 1 Rioted 11/29/2016 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Edge Energy, LLC County AIRS ID 123 Plant AIRS ID 9EEC Facility Name Long 22-B Emissions - uncontrolled (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP08 Produced water storage, 500 bbl 1707 5364 3.5 002 16WE1136 Loadout 54 473 0.3 003 16WE1137 Condensate storage (1000 bbl) 803 493 43 193 5366 85 3.5 004 GP02 GM FX10 (5.7L), sn: 10CHMM30527003 237 33 31 18 36 0.2 APEN-Exempt / Insignificants XA Heater 6 0.0 XA Fugitives 1 1 1 2 4 1 0.0 TOTAL (tpy) 0.1 0.0 0.0 1.3 0.2 0.0 0.1 5.6 0.0 0.0 0.0 0.0 7.5 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP08 Produced water storage, 500 bbl 86 269 0.2 002 16WE1136 Loadout 54 473 0.3 003 16WE1137 Condensate storage (1000 bbl) 40 25 2 10 268 4 0.2 004 GP02 GM FX10 (5.7L), sn: 10CHMM30527003 237 33 31 18 36 0.2 APEN-Exempt / Insignificants XA Heater 6 0.0 XA Fugitives 1 1 1 2 4 1 0.0 TOTAL(tpy) 0.1 0.0 0.0 0.1 0.0 0.0 0.0 0.5 0.0 0.0 0.0 0.0 0.8 1239EEC.xlsx 11/29/2016 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 16WE1137 Issuance 1 DATE ISSUED: ISSUED TO: Edge Energy, LLC THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Long 22-B Pad, located in the NENW of Section 22 of T1 N R65W in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description LOAD -1 002 Truck loadout of condensate. Emissions from the loadout are not controlled. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.00v/pacific/cdphe/other-air- permittinq-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Cdhtrol Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source AIRS ID: 123/9EEC Page 1 of 7 Condensate Loadout TM Version 2012-1 Public Health and Environment Air Pollution Control Division within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall retain the permit final authorization letter issued by the Division after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type VOC LOAD -1 002 15.6 Point ee "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. PROCESS LIMITATIONS AND RECORDS 6. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit LOAD -1 002 Condensate Loading 131,400 bbl The owner or operator shall calculate monthly process rates based on the calendar month. AIRS ID: 123/9EEC Page 2 of 7 Public Health and Environment Air Pollution Control Division Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 7. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section I I.A.1. & 4.) 8. This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E) 9. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 10. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. b. All compartment hatches at the facility (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. The owner or operator shall inspect onsite loading equipment during loading operations to monitor compliance with above conditions. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 11. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. OPERATING & MAINTENANCE REQUIREMENTS 12. This source is not required to follow a Division -approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING 13. This source is not required to comply with any testing and sampling requirements. AIRS ID: 123/9EEC Page 3 of 7 Public Health and Environment Air Pollution Control Division ADDITIONAL REQUIREMENTS 14. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone nonattainment areas emitting less than 100 tons of VOC or NOx per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 15. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 16. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 17. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences AIRS ID: 123/9EEC Page 4 of 7 Public Health and Environment Air Pollution Control Division and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self - Certify for Final Authorization section of this permit. 18. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 19. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 20. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 21. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 22. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Andy Gruel, P.E. Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Edge Energy, LLC. AIRS ID: 123/9EEC Page 5 of 7 Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emission Rate (lb/yr) Are the emissions reportable? Controlled Emission Rate (lb/yr) 002 Benzene 71432 54 No N/A n -Hexane 110543 473 Yes N/A 5) The emission levels contained in this permit are based on the following emission factors: CAS Pollutant Emission Factors lb/BBL loaded - Uncontrolled Source VOC 0.236 CDPHE Default for Condensate Loadout 71432 Benzene 0.00041 110543 n -Hexane 0.0036 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC AIRS ID: 123/9EEC Page 6 of 7 Public Health and Environment Air Pollution Control Division 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A — Subpart KKKK NSPS Part 60, Appendixes Appendix A — Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A — Subpart Z MACT 63.600-63.1199 Subpart AA — Subpart DDD MACT 63.1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXXXXX 9) A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9EEC Page 7 of 7 Permit number: Date issued: Issued to: DC? on - trol Division Department of Public Health & Environment CONSTRUCTION PERMIT 16WE1137 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Edge Energy, LLC Long 22-B Pad 123/9EEC NENW Section 22 T1 N R65W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TK-1 003 Two (2) 500 barrel fixed roof storage vessels used to store condensate. Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) COLORADO Air Pollution Control Division v�uw sne-n - i Public tieait:;. Page 1 of 7 3. p- i al exp if e owne''•r operator of the source for which this permit was issued: do- `" •t •' en ructi. ` odification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO TK-1 003 --- --- 10.3 1.7 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to ca limits. Compliance with the annual limits for criteria pollutants shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled TK-1 003 Enclosed Flare VOC PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit TK-1 003 Condensate throughput 131,400 barrels COLORADO Air Pollution Control Division De rntrt CI' Pubs! lean .b E'rz<vurr-r_?tt Page 2 of 7 monito onthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING E MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to COLORADO Air Pollution Control Division t lea€;ra t1 s:,rirurlr.ri< ft Page 3 of 7 g basis with the requirements of this permit. Revisions to pproval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16) Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone nonattainment areas emitting less than 100 tons of VOC or NOx per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. COLORADO Air Pollution Control Division +Depanm r:P Z'ii PUL L£ kjesalt?, S E irorvrimt Page 4 of 7 20. A s €"r s• `cifi� ly .tes thfinal authorization has been granted, then the remainder thi " d n .'.. "'able. • erwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Andy Gruel, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Edge Energy, LLC. COLORADO Air Pollution Control Division 3epar ;rwra et Pal&:. Hea ts: 7s _",-virus nr:e'r[ Page 5 of 7 No this "- it issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-reps 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 003 Benzene 71432 803 40 Toluene 108883 493 25 Ethylbenzene 100414 43 2 Xylenes 1330207 193 10 n -Hexane 110543 5366 268 2,2,4- Trimethylpentane 540841 85 4 Note: All non -criteria reportable pollutants in the table above with uncontrolled 20 emission races aoove pc per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 003: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx --- 0.0053 AP -42 Ch. 13.5 CO --- 0.0239 AP -42 Ch. 13.5 VOC 3.132 0.15659 Promax model based on site - specific pressurized liquid sample collected 9/7/16 71432 Benzene 0.006 0.00031 108883 Toluene 0.0037 0.00019 100414 Ethylbenzene 0.0003 0.00002 1330207 Xylene 0.0015 0.00007 110543 n -Hexane 0.0408 0.00204 540841 2'2'4 Trimethylpentane 0.0006 0.00003 'COLORADO Air Pollution Control Division bUc He Jb fi rrru onr� pit Page 6 of 7 actors f a this point are based on the flare control efficiency of 95%. NOx ssi. : " wer ::""'-d on a gas content of 2226.44 Btu/scf and a volume of gas of 34.69 scf/bbl, both of which were modeled by Promax. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC PSD or NANSR Synthetic Minor Source of: VOC MACT HH Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division Jit:;}?li`li4 ti1'�U�IS� Flea x'1.:1 ��•^<V'/J'1!•'.;?li Page 7 of 7 uid Loadin C I- Le C L ci 3 Permit Number: Facility Equipment 1D: nested Action (Check applicable request boxes) Section 02 — Re General Permit GP07 Individual Permit Action Applies To: Section 01 — Administrative Information C L L a o • d al 2 N a O V E Y • a O A a a eYo a 4 V 0 V Z A� m D a a a t U a. a• c Cr 41 acgV 40 r. at Do S ❑ ❑ ❑ ❑ 0 Transfer of ownership J —J T rn 0) C LU 0) O W Company Name: t0 N N O) C J Source Nam NENW Sec. 22 Ti N R65W Source Locatio N C O C.) 621 17th Street, Suite 1401 Mailing Address: Change permit limit d L4 C,, U, O cn 0 .a 0) u) O U > C fl W a E a Y L .O C Y Y U U- a 0 d C a M O) N O C) a LU a Y 0. E u Y a a E a a a a a O 'E W a a z a w c• 2 a a IZ.ra u u a a a CP O • C C 3 Person To Contact: Ben Turner r@edgeenergy1.com E a z Addl. Info. & Notes: U days/week 52 a 0 C 0 L N Normal Hours of Source Operation: a C a a a a L Y a Y V O a 0 U Y t/1 O N N 00 > 3 0 0 3 . 3 A a AAA o O DOD z z z z z • [7] [300 Truck load out of condensate from the pad. < < < w y y 2 H41 O 0 ❑0 U N a .V+ a C N O C V 0 O G. 00 a N a C a O a O C. C e C1..003 LU dl L c, a E v a 2 N ` 7 .7,,o C He C e y .3 E�'00 . • g Lj+ a Y c u Y y '00 y „a; u L • Toa E C. r L 7 N > i 3 v00 L C O Up a y o .eoE a E u a u p > L CO C. r. 00 -NC o v4aoa A,U 8cn U 3N o r 7 S L: c c° a - o o A U> •a u Din oPU.$ aai axi c i U Q e A LU o` o = N v., N N N 00$ O O O r Nl M a • Ch C Na '5 •= e C Y O .C tr C < APEN forms: Permit status: C7 1 ♦ ♦ ♦ c/) Y S N a a .oa 4.4 2 I— C Co O Y i o c y I p A 4 C `j •'2 C -0 a m S C Q ; Ut y a0 �¢2 u O a L O V a 0 fl Y o 4 2 A a al FormAPCD-208-HydrocarbonLrgmdLoadmgAPEN-Vern 4-14-2014 (1) docx LCD Cr) FORM APCD-208 7 'C R 2 CO 0 O a .O Ce E C O a C ..3 C H L e a Ce 0 4 Ce a u Ce Permit Number: CU s 471 CO 0d J E U y C E U e c 4 a v. V: 17 O a a e U O N 'ID M O O -104.650917 (C9 0O a z Ia .' C L Q F.,- ... O. c Z C' Section 08 — Emissions Inventory Information <O 0 c E a a O 'C C 0 V N m 0 0 0 a y C m J c 0 C y V Ca a a y a a 0 N 0 ed C O u U7 C a a a ae L a a d 0 C, E Cd C R u n C R L d a L a ✓ C E L u SM c C) CO .0 L. d a C C a L O L C 0 a Ecc Z LL w a) N^ V/ z w 4) VJ w 4) VJ Actual Calendar Year Emissions' o c� 0 z L.6 z O ca O z L() Q z O O N O Q z N O N a z N O O O N O Z N O N r Q z N O O O N Emission Factor Q z .` Q Z N 01 .0 Q g z C O U C (O M N O Q Z O u O 9 Cri O Control Device Dc a C O v a Identify in Section 07 a e C C E Ce a R • e c y L OS _ C o t i e Y E w, O O 9 V t z m .�. V C u a 7., C a J CC IA E S .71 ` a L T H d e .E • L n. .J. 6..� y' L C) C" r s. -2:y L Vf., E s ;11; L - O.ZC d y- —, C C aC ` • .. - T L R !3 *= G. m \ _'' 13 w 0. ▪ 3 v _ - 6 ( j I. o o C C1 = lY 1: Lr 4 I CL Gr Is L 17i kt L ti L' > O C) 2 X U c a C — a L p N N l l co a it 4 a v .0 > V E E u • Ce 1� I. • C I: a t - u W c, a a r C a s::, V E c 6. y' E ^"5 e >. G• U 'CCy T S.G - c0 cV c ✓ C.. `d y R 0 C i U V O C o0 Q ° o a E - o c "E cn 6J G a C -o V N v c .a s_ C 3 >, = •E e a C C) CO G C o a o C C 6CJ V = G N a _ H C oN 0 z C DJ V CC 7 C as G a u e O. Li C Ol L O c .c ,3a a r`\ a a N v c i a O \. Permit Number: Facility Equipment ID: Section 02 — Re Section 01 — Administrative Information .W €-4❑ 7 ❑❑ a ▪ . r o O r s In 41 A 01 14 • ❑ L .0 O 4 Y G 4.1 a E wV ▪ L a.. • E 4°. ° d a 8 0 -0 . Y ▪ Y C g t 2 V F C o A 0 L y V A O 40 °.:r] H E p ° E Q °' E W o w C7 o 0. Y z .5 li .4-. @ z �"� 0 6. o Y a y L L A U v: I = ca a. z = p 0 L. I. ismso e lossi 0.. 4 L L C • > d C.7 an u U U C C C W k7 a a❑ z ▪ ❑ ❑ 0 0 w. v. ssmi N GV U z v� z 0 3 1M� a O 00 5 G 0 o N z N CA W Source Location: Y C Y V P. 0.4 Mailing Address: Person To Contact: z 2 z b N 00 } } ❑0 aa 0z zz Pn N I❑ •_ ® ❑ N N � } T y = 3 - I® Normal Hours of Source Operation: by > Y O E. tC. % = C w y ,40 w T'b M ' A d 7 W w `° r� g pre at I C '= 0 a Q SN,, O e Y p N L N Y O qq D 'p .L `u es a 12'0 0+ ... C oL° a... I_ C 0.V O\ 0' 674 7 y x •5. N y C N yI Y O p� A O y f 9 tN vc,�E 'as-. 0 y xw n._ yY E A x c :Qz�ve0d .s I o W ai 0 TA a- .0 e n= o ° �t O. ° 7 rj O O; a o . o. CI U y G. Y 8 • -. UI y. ≥ y O O O U ^ 0) A "lit= 5 ° ° {Q. 3 a 'y ° ° A C " e• t L C y O 'm �A F7 w'• LN = pa a )Ez _�Zyo, Ur, o U� G 'vas 0 vim,y OQC1 r.'O cc. o.5 o=• 3 c.3_eQ a9CcA •fl �m o 0 E« Eve, i A U Y a i V >' €: A Y '. p 0.O y `' 4 �a�9'2wa- QCVQec u ¢z 0 O 0 00 VI in + N M r In ;Al 0,1 'ab riiilm O O O t cn CI o w a. v p C' 0 U U .0 a a g n e U ON ❑ External Floating Roof: 0 0 a) 0 00 N 0 F C 4 Y ° V L 0 O Da la E O A N 41 O Y Q h o aa as ea O 'D 0 00 o 00 A C 7 y A- y •e > as 00o V] o v� N N L z Name or Well Loog 22-15bNCH API Number U 0 5 vi aI N w C. FORM APCD-205 AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Condensate Stora Emission Source AIRS ID: Permit Number: Location (Datum & either Lat/Long or UTM) Source. if no combustion Section 06 —Stack 0. EU F v c2z 5, y 2 -00 001 ? t V Other (Describe) ❑ rural with obstru n of stack out Width (inches) _ Circular: Inner Diameter (inches) _ E&P Sites On Information aration Technolo 00 C V 00 V V r m 0. 00 1 - Heater Treater CO N A O t aJ 71, 3 3y C G 0. y V N A 9. Information Emission Factor Data Source 0. Q O 4, 0 G. O o.. O G_ O 0. O 0. O C tort pollutants not listed above. _ I Requested Permitted Emissions IControlled (Tons/Year) V? ,n C 'IN N,40 V r N = O 0 C 0 0 O 0^ G G G 52 O C Uncontrolled (Tons/Year) r tomC O 0.25 0.02 O OO '0' rn V) V ? `O O 0 0 0 G N O N Actual Calendar Year Emission' Controlled (Tons/Year) N 8.57 1.34 0.02 0 0 0 +! O Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to re 0 O 0 G C O Uncontrolled (Tons/Year) J N 171.47 1+1 N1 N O O N G O O O O 0 N O u.ucuw..�u ■.w..ucv vow Ia.... ••.. Emission Factor Units C a.3 a L tz 2 3 3 a I Uncontrolled Basis 07 r.4 — 'pO M O ,r O CO M O O O O O 2 G 'n O C C C C O t i cmusnw ruciur riot Pollutant Benzene 4) N C N . G N U O O C. N x 78 r A j N C CUq W c N N Ben Turner c 0. N 4) 0 C 0 4) 0. ",r4.11 O_ TO C C FmF • C N a Z .7S4 LCI�] S 7 4) o u C 121 z AP Form-APCD-205-Condensate-Tanks-APEN.doc N 0 a N N 40 a FORM APCD-205 Hello